The Luxembourg Commission de Surveillance du Secteur Financier (CSSF) published an update on transaction reporting under Article 26 of Regulation (EU) No 600/2014 (MiFIR), covering the supervised entities in scope, the volume of reports received and the supervisory initiatives it uses to raise data quality. The CSSF underlined that transaction reports support a growing set of supervisory and analytical use cases beyond market abuse surveillance, increasing the need for accurate and reliable reporting. As of 1 January 2026, 105 Luxembourg credit institutions, investment firms and authorised branches of third-country firms were within scope, down from 119 as of 1 January 2023. The CSSF received 37,741,152 transaction reports (including cancellations and corrections) in 2023, 23,034,123 in 2024 and 23,976,836 in 2025. Data quality monitoring combines recurring tests, including the CSSF’s Quarterly Analytical Summaries, cross-checks between suspicious transaction and order reports and related transaction reports, and consistency checks between transaction reporting and order book data for trading members on the Luxembourg Stock Exchange’s regulated market (XLUX) and multilateral trading facility (EMTF), alongside ad-hoc tests targeting issues such as branch country fields, price outliers and incorrect use of MIC codes versus XOFF when using an internal aggregate client account. While noting broad progress, the CSSF flagged firms with limited improvement and stressed ongoing self-monitoring via submission feedback files, use of CSSF data extracts and proactive error notifications; it also required firms found to report inconsistent natural person identifiers to correct them and not execute transactions for flagged clients that fail to provide a correct identifier. The release also highlighted specific fields as critical given ESMA’s decision to calculate the Single Volume Cap Mechanism using transaction reporting data, including the trading venue transaction identification code, venue identification and waiver indicator fields. On the evolving framework following the MiFIR Review (Regulation (EU) 2024/791), the CSSF noted ESMA’s decision not to propose changes to the MiFIR transaction reporting, reference data or order book data frameworks at this stage, and instead to launch a call for evidence on simplifying financial transaction reporting across MiFIR, EMIR and SFTR, with a final report planned for the beginning of 2026. The CSSF also pointed to the continued application of existing delegated acts until revised and stated it will keep closely monitoring reporting quality under the current requirements over the coming years.
Luxembourg Commission de Surveillance du Secteur Financier 2026-02-26
Luxembourg Commission de Surveillance du Secteur Financier reports 105 MiFIR transaction reporters and reinforces data quality remediation expectations
The Luxembourg CSSF updated on MiFIR transaction reporting, noting fewer supervised entities and stressing accurate reporting's importance. It received over 23 million annual reports from 2023 to 2025, emphasizing data quality monitoring and corrective measures. ESMA decided against proposing MiFIR reporting changes but seeks evidence to simplify financial transaction reporting.